DRC-2010-003481 - 0901a06880190307

State ofUtah
GARY R. HERBERT
Govemor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Dane L. Finerfrock
Director
010
010-0034
June 3, 2010
Certified Mail
(Retum Receipt Requested)
Ms. Jo Ann Tischler
Director, Compliance and Permitting
Denison Mines (USA) Corporation (DUSA)
1050 n"'Street, Suite 950
Denver, CO 80265
Dear Ms. Tischler:
SUBJECT: Denison Mines (USA) Corporation (DUSA) White Mesa Mill Facility
DRC Inspection Results: Ore Storage Pad Area, Tailings Cells 1-3 DMT and Cell 4A
BAT Performance Standards and Monitoring Inspection Engineering Inspection Module
75E; Report of Findings and Request for Information
An inspection on the subject was held on May 4, 2010 at the DUSA mill facilities near Blanding, Utah.
Messrs. Phillip Goble and David Rupp represented DRC, Messrs. Rich Bartlett, David Turk and Ryan
Palmer represented DUSA that day. Later that evening, Mr. Rupp also spoke with Mr. Frydenlund of
DUSA regarding item 2 below. Our fmdings and requests for infonnation are identified below:
Issues Identified, Remedies Proposed and Requests for Information
1.
2.
Ore Storage Pad Buffer Zone. Along the southem border of the ore storage pad area, ore-like
appearing materials were noted to be in contact with the fence. The depth ofthis material in
contact with the fence was about 2-feet. Mr. Bartlett of DUSA offered to remove the material
that day, which was accepted by the DRC representatives. The 4-foot buffer is a current
requirement of the DMT Plan, and if the current permit changes are approved, it will be a
Ground Water Discharge Permit requirement as well.
work. We request DUSA supply a photograph of this completed
Pooling Water. Pooling water was observed up to about 50-feet in radius, surrounding the tall
vanadium pregnant liquor tank and water tank east of the Mill building. Sources for the water
appeared to be storm water run-on, direct precipitation and steam condensation. At our exit
meeting at the White Mesa Mill Administration Office, various proposed configurations to
eliminate this water pooling were discussed.
However, as mentioned above, Messrs. Rupp and Frydenlund spoke about this item later that
evening. It was discussed that DUSA needs to assure that the area around the tanks fully
168 North 1950 West • Salt Lalte City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq. Utah, gov
Prinled on 100% recycled paper
Ms. Jo An Tisihler
June 3, 2010
Page 2
drains to Cell 1. Complete drainage to Cell 1, rather than pooling or retention of water, is a
requirement of the DUSA Storm Water Best Management Practices Plan (SWBMPP).
In our discussion on May 17, 2010 you agreed that this work would be completed on or prior
to September 30, 2010. We acknowledged that response to this item may include required
provisions for leak containment of the VPL tank. Completion of this work will be verified
during the annual DUSA storm water management inspection by DRC to be conducted this
fall.
3. Apparent Narrow Travel Lane on the Dike between Cells 4A and 4B. During the May 4, 2010
inspection, Messrs. Snyder and Bartlett indicated they were considering using fences and gates
to contro] access to the narrow travel lane on this dike, and that only certain traffic would be
allowed. No photos or measurements were taken during the inspection. Later, we expressed
some concems that the total dike width may be too narrow. On May 19, 2010 Mr. Harold
Roberts of DUSA telephoned with measurements, stating the dike met or exceeded the current
construction width requirements.
4. Surveying of Settlement Monitors: Recommendations for Improvement. It appears there may
be potential error reduction if DUSA used a more organized ledger form for collecting and
reducing survey notes. Avoiding long distance survey rod readings by using tuming points,
additional benchmarks or other methods could also significantly reduce errors. These actions
may produce less erroneous data for the analysis, explanation, correction and resolution
required in proposed new License Conditions 11.7.Eand 11.7.1.
In telephone conversations with you on May 17, 2010 we discussed the items above. You committed that
DUSA would fully respond to this letter within 45 days of receipt. Feel free to contact me if you have any
questions.
Sincerely,
David A. Rupp, P.E.
Geotechnical Services Section
Cc: Thomas Rushing, DRC
Dean Henderson, DRC
Harold Roberts, DUSA
F:\drupp\DUSA\ InspeclionsVDMT&BATJ^FIl 06-IO.doc